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R vs Sang || 1980 [AC] 402 || Case Summary


Police

R vs Sang Case Summary

Facts:

- Defendants (Sang and others) accused of conspiring to import and supply cannabis.

- Undercover police officer infiltrated the group.

- Defendants argued entrapment.

 

Issues:

1. Whether entrapment is a valid defence in English law.

2. Admissibility of evidence obtained through undercover operations.

 

Held:

1. Entrapment is not a defence in English law.

2. Evidence obtained through undercover operations is admissible, but subject to guidelines.

 

Guidelines:

1. Undercover officers must not instigate or encourage crime.

2. The officer’s role should be passive, not active.

3. Evidence obtained through entrapment may be excluded.

 

Rationale:

- Entrapment is not recognized as a defence to prevent abuse of process.

- Undercover operations legitimate investigative tool, but require careful management.

 

Impact:

- Established guidelines for undercover operations in the UK.

- Influenced the development of entrapment law in commonwealth jurisdictions.

 

Key Points:

1. Entrapment not a defence in English law.

2. Undercover operations require careful management.

3. Evidence obtained through entrapment may be excluded.

 

                                 ~ Maihar Sundaram Singh ♤

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